Ravenshead Parish Council Opposes the Acceptance of the Planning Application on the Following

Response by Ravenshead Parish Council to Gedling Borough Council`s consultation on Planning Application No. 2007/1094 - Land to the rear of Sand Hole Wood, Longdale Lane, Ravenshead.

Ravenshead Parish Council opposes approval of the Planning Application on the following grounds.

1)The case made that the factory is an appropriate development in the green Belt is unsustainable.

2)We find it difficult to understand why a new access to the existing site from Leapool Roundabout has been examined but was rejected because of prohibitive cost. The Ravenshead site is planned to have a new road with a 7.3 metre carriageway and 2 metre-wide footway together with significant other necessary infrastructure. If they cannot afford one, how can they afford the other?

3)Hammond Produce Limited (HPL) will run the operation for Sherwood Produce Limited (SPL). SLP is a conglomerate of farms but HPL is a packaging company. The application admits that the proposition is not in itself an agricultural operation within the strict definition of agriculture in the Town and Country Planning Act.

4)The development comprises a combination of UCO Classes B2 and B8 employing a substantial number of people (175) and falls within the ambit of Employment Development.

5)The construction itself includes a huge steel portal frame structure, providing nearly 6000 square metres of floor space, an obtrusive tank farm and a 67 car parking lot – all set on the skyline of a ridge. Not only does it provide space for the Conglomerate HPL operation, it also gives office accommodation for SLP staff. This is clearly an industrial factory and could not be described as a farm-gate operation. The whole concept and its ridgeline position are both unacceptable.

6)We notice that the Development Site plan 6478S-100 contains north and south extensions on the eastern side of the site. The north extension runs up to an internal site road. The south extension runs down to a gate almost at Longdale Lane. We query the reason for these extensions to the Development Site. Why are they included and is there any intention that they are used as alternative means of entrance or exit from the operation in future?

7)Significant benefit is claimed about the shielding of a view of the site from Longdale Lane by Sand Hole Wood. This is less significant from Rigg Lane and we have concerns about the unmentioned views from the Scout Camp and from the higher points on Chapel Lane.

8)The application argues on the one hand that the plant will do no more than that typically carried out at the farm gate and on the other hand justifies the plant because it reflects encouragement to farmers from Government and the EU, to move progressively down the supply chain so as to add value and enhance quality and provenance to the product. We would argue that the scale of packaging envisaged, which makes the product immediately saleable in supermarkets, goes far beyond the factory gate into a separate business culture.

9)And, further, the proposal argues that to acquire industrial land at prevailing values…..would render the agricultural product uncompetitive in the market. This proposition, if accepted, leads inevitably to the conclusion that this work has to be performed on a Green Field – although not necessarily on a Green Belt Field. We would not accept the proposition in the absence of any supporting evidence and without any information about how other farmers deliver vegetables to supermarkets. The proposal adds that another advantage of a Green Field site from their point of view is that there is an opportunity on the Application Site to provide for future expansion of the operation without the need to advance purchase and hold land at considerable capital and revenue cost to the Applicant, as would be the case with an industrial estate. So, we see that this would be a win win situation for the Applicant, advanced on a financial basis, but without the provision of any factual financial justification. We do not accept this proposition as it stands.

10)The proposal argues that the plant will meet only two of the six objectives for Green Belts (PPG2) – to retain nature conservation interests and to retain land in agriculture, forestry and related uses. We would argue that both of these aspirations would be jeopardised to some extent by approving this Application and that both would be better served by avoiding building the plant in the first instance. Without this development our existing protected wildlife would retain their existing environment and the land would continue to be devoted to agriculture. We notice that the Ecological Survey makes no mention of the Roe Deer which inhabit the Sand Hole Wood nor the effect this will have on their desired retention in this location!

11)We read a detailed account of the excellence of the design of this factory, its green credentials and its environmental friendliness. But, all these design advantages will exist wherever the plant is eventually located and they should not be considered as any justification for sighting it on Green Belt land.

12)Precedence arguments are already being used as justification for this application, and we fear more will follow in the future. Thus it is argued, The development involves the substantial relocation and expansion of an existing development which is itself already located in the Green Belt (at New Farm Redhill) – so why not let us build another bigger and better one as well? Or, HGVs currently access the farm on Longdale Lane and hence the principle of these movements is already established, so why not let 70 such movements take place every day despite a ban on HGV movements on Longdale Lane?

13)We must record that we believe that the existing HGV movements are themselves illegal since they transgress the instructions on the relevant road signage. Any relaxation of the restriction of heavy goods vehicle movements for 70 SPL HGV`s per day down Longdale Lane will inevitably allow other such vehicles, such as the Tarmac concrete lorries, to then access the A614 from the A60 at Kighill. Hence, we would create a Mansfield to A614 route for HGVs running through RavensheadVillage!

14)The Application is full of self-praise about conferring considerable amenity benefits on residential properties at Redhill, together with the elimination of existing noise and disturbance to householders on Thornton Avenue! But, it neglects to indicate that all this loss of amenity, together with the noise and disturbance generated will be re-visited on the homes and businesses close to the Ravenshead proposed site. Worse, it even calmly suggests that the new plant is remote from residential and other sensitive properties, eliminating the harm to amenity arising from the operations! Nothing could be further from the truth.

15)The proposed site for this factory sits on a designated brown route to Sherwood Forest and is actually in Sherwood Forest itself. This local area is heavily involved in the promotion of local Tourism with such facilities as the Longdale Rural Craft Centre including a restaurant with patio dining, the Abel Smith Scout Camp Site, The Papplewick Pumping Station and the Horse and Cycle Tracks provided in Blidworth Woods by Forest Enterprises (Forestry Commission). Cyclists, walkers and horse riders regularly access these facilities via. entrances on both sides of Longdale Lane and the extra intensity of heavy and slow moving goods vehicles would severely jeopardise these Tourism and leisure initiatives. Longdale Lane is now a very busy 60mph road with a Heavy Goods Vehicle prohibition and no footpath, cycle lanes or street lighting. There are eight residential homes, a SutherlandHouseSchool for Autistic children brought there by special vehicles and the Longdale Craft Centre, all within shouting distance of the proposed Application Site. These properties will inevitably suffer the very same unacceptable disturbance as those raised by complaining Thornton Avenue residents. We believe that many other properties on Longdale Lane will also be severely affected including the LongdaleNursery School and the homes situated between Kighill Lane and the site entrance. There will also be problems with the two Forestry Commission car park entrances, egress from Rigg Lane and a clash with the Car-Boot Sale providers. These properties will inevitably suffer the very same disturbance as those raised by complaining Thornton Avenue residents. Properties on the Ravenshead side of the entrance to the site already complain about egress difficulty because of traffic flow and the additional slow moving vehicles imposed by this development will surely exacerbate this. There will be severe loss of amenity by many Ravenshead residents.

16)This is a 24/7 operation, wholly inconsistent with a rural setting.

17)There is ambivalence about the scale of the operation. All the consultants` work, such as that for transport and travel, is predicated on the existing staff and vehicle movements at Redhill on one particular day, with no indication of the highs and lows of the growing seasons. But, the Application also indicates that a purpose of the plant is to significantly increase processing and packing capacity in the short term and to afford scope for future expansion in the medium/long-term. The existing plant is not big enough to cope with current demand and business, therefore, is being turned away. The proposal also states that most of the existing operations at the existing site at New Farm will be transferred to the new development, but in another part of the Proposal we are told that The existing plant at New Farm, in which there has been considerable historic investment will be retained, with some rationalisation and re-planning, for dedicated processing and packing of a limited amount of produce on a much-reduced scale. Thus, question 4 of Part 2 of the application form is not properly answered about retention of the existing plant and question 8 of the same form is effectively avoided on the question of actual traffic flow. We have no conception of the increase of scale from Redhill to Ravenshead, nor the increase in volume of Tractor-trailers and HGVs. Neither are we sure that the numbers of employees indicated in box 6 will cope with the “significantly increased” production stated. Therefore, the offered Transport Assessment study and the quoted 70 HGVs per day are also invalid. We also have no idea how significant will be the claimed amenity benefits on Thornton Avenue unless we know the planned scale of the retained Redhill site nor the possibility of work expanding there in the future.

18)Question 2 of Part 2 of the Application Form asks if the Application forms a stage of a larger scheme. The question is avoided using a “dash” placed in the answer box. But, the Proposal makes clear that an advantage of this Green Belt site is its propensity for expansion in that it states that the new site will afford opportunity for future expansion in the medium/long-term. SPL has expanded significantly since its inception and this new and extended facility for packing could well produce further expansion. The Proposal anticipates this possibility but makes no prediction about ultimate capacity, although we wonder why the Application Site is twice as big as necessary for present need. The scale of the ultimate plant is unknown, or at least undeclared.

19)There is no indication given of the environmental consequences of this 24/7 plant in terms of light, air and noise pollution generated by road vehicles or by the plant itself. We read that there will be a 500KVA generator and a Cyclone operating on site without detail about noise generation. We anticipate significant disturbance from backing vehicle beepers. We also read in the Environmental Statement that machinery is envisaged to convert 9,000 tonnes per annum of rape seed into 2.8 million litres of biodiesel (Phoenix Fuels Ltd). It is not made clear where this process will be safely carried out nor where the diesel product will be stored.

20)Reference water usage for the washing processes, we read that washing water usage on site will be in excess of 30 cubic metres (m3) per day, including 20m3 from a borehole. We expect there to be a need for a licence to permit the borehole and the use of 20m3 per day for washing purposes. The supply in excess of 30m3 will come from the town mains, but the quantity is either unknown or undisclosed. 30m3 per day is three times normal rainfall. We read that, after use, all this water will be discharged via. a cyclone and a reed bed to a nearby watercourse. We are unaware of the location of the “nearby watercourse” mentioned in the papers. Ravenshead residents, particularly those who live on Longdale Lane, know that our road drainage system is inadequate for average rainfall at only 10m3 per day, because we have no watercourse available, resulting in regular flooding of the highway. We have no assurance that this extra water volume, in excess of 20m3 per day, could be disposed of without more serious flooding.

21)Sewerage disposal from Ravenshead is by gravity feed to a pumping station adjacent to No. 225 Longdale Lane from whence it is pumped away to Blidworth/Rainworth. Houses beyond No.225, and hence the Development Site, are required to use Septic Tanks to prevent discharge which could affect the drinking water quality of the aquifer underneath these properties. The Application does not make clear how the sewerage generated by 175 workers at the plant will be dealt with, other than to show on one of the plans, the site of an “underground non-trade effluent treatment plant”. How effective this would be, whether discharges will be allowed from it to the aquifer and how it would be quality controlled is all unexplained. We therefore have concerns.

22)Road safety on Longdale Lane becomes a significant concern with the introduction of significant traffic movements daily in and out of the site entrance on a road with blind bends in both directions and the national speed limit of 60 mph. This is particularly problematic with the introduction of slow moving tractor-trailer units and HGVs to the road mix. The transport assessment, we are told, follows conventional rules and bases the calculation of breaking distances and visibility splays on average vehicle speeds of 45 mph. But the one-day study on the 7th June 2007, whilst producing this average speed, also identified some 13% exceeding this level, including one vehicle at 65 mph. We would argue that, on this winding road, the breaking distance visibility splay calculation should be based on a speed of 60 mph, extending the breaking distance from 160 metres to 215 metres. The extended splay would then move back to the Scout Camp bend on the west side of the entrance effectively obscuring the sight of the entrance itself from that point. Egress from business and domestic properties along Longdale Lane is already very difficult because of the combination of the winding road and the excessive speeds of some traffic, including motorcyclists exceeding 80 mph who seemingly cannot be controlled within the speed limit. Slow moving, and slow moving turning vehicles also encourage overtaking and the report says little about overtaking sight distances on the road through to the A614, which not only has sharp bends but also the concealed entrances to two Forestry Commission public car parks mentioned earlier.

23)There is considerable credit taken in the Proposal for the saving of “food miles” consequent on the fact that produce would have a 6.4 kms shorter journey. However, it is clear from the proposed provision of 67 car parking spaces, that 70% of the personnel will travel from Arnold in motorcars, adding 6.4 kms to each of their journeys. And, 19% of the personnel who currently walk from the A60 bus to the Redhill plant will now need a shuttle bus ride to the new plant. Thirdly, the Travel Plan indicates that 10% of the personnel movements are currently by Bicycle, but we feel it to be very unlikely that many people will be brave enough to cycle to work in the new location, along unlighted 60mph roads from Arnold, or via. Hucknall on the Sustrans Cycle Route, and will resort to vehicle transport. The Proposal neglects to include these considerations in their calculations and we anticipate that the whole process of transportation is likely to be carbon neutral, not carbon negative as claimed.

24)There is some confusion about multi-modal transportation of workers to the site. We are offered a statement which says that the Applicant will initially provide a free staff minibus services from the bus stops adjacent to the existing New Farm site at the start and end of shifts. Over time the home locations of staff will be monitored and the minibus service developed to meet demand, to complement public transport services and thus minimise the use of private motor vehicles by staff. However, the Travel Plan provided indicates that multi-modal travel by staff will be by Pronto bus to the Kighill stop on the A60 and thence by a minibus shuttle service between Sand Holes and Kighill. With this latter alternative, there seems to have been no consideration or indication about where this shuttle minibus will park to await the staff nor how staff are going to get across the busy A60 at Kighill in the dark at rush hour! Which of these two systems of multi-modal movement is intended?